Shortly before Christmas 2010, ‘Lifetime Recycling Village Ltd’, a new enterprise formed by businessman Brian Kilgour announced that it had submitted a scoping report to the Scottish Government. Brian Kilgour is also the Managing Director of a separate company called Lifetime Recycling Ltd.

The purpose of the report was to initiate the national planning process under Section 36 of Electricity Act 1989 in order to obtain permission to construct the largest waste to energy and recycling centre in Europe. This to some extent by-passes the local authority planning process, although it does provide for objection by “interested parties” such as the Local Authority, local interest groups et al. and must still comply with local and national regulations on planning and emissions.

The new £640 million facility will cover 27 hectares (equivalent to 27 international rugby pitches and almost six times the size of the new Southern General superhospital). It is to be constructed at Loganswell Farm, which is purported to be designated for green energy projects and is three miles from Mearns Cross. It is intended to process at least 1.5 million tonnes of solid commercial and domestic waste taken from the 11 nearest Local Authority areas in central and southern Scotland.

The waste will be processed through a conventional recycling stage (removing non-organic waste glass, metals and the like). Recycled waste will initially be recycled offsite, but is intended that on-site waste management companies and manufacturers will join the venture, making this a complete recycling facility with virtually no offsite removal other than recycled products.

In accordance with current limits, some 370,000 Tonnes of waste per annum will be taken for thermal treatment at the facilty. This particular thermal treatment process is generally described as a combined process of gasification and plasma pyrolysis. The main product will be syngas (consisting mainly of Hydrogen (80%), Carbon Monoxide, Carbon Dioxide and Methane). A product of the gasification and pyrolysis stages is a stabilised vitreous product capable of use as construction materials and a small remnant (1.5%) of unusable material that would be sent to landfill.

This syngas will be used to generate around 100MW of electricity in a conventional power station consisting of a boiler and steam turbine which in turn will power the site with the excess being sold on to the National Grid.

The project had been presented as a “green” “village” and an ideal counterpart to the Whitelees Wind Farm. LRV’s website states that the project will create 1,000 jobs, although its media release and letters to residents put the figure at 700. Job totals in excess of 2000 are quoted for the region as a result of downstream manufacturing potential.

The local community is told that the facility will provide significant benefits, including a £250,000 annual community fund and a visitor centre. Local residents will be given an opportunity to specify the exterior and roofing finish of the structures that make up the ‘village’.

Local media reports indicated Brian Kilgour’s interest in Loganswell Farm as far back as 2008 and site investigations were understood to have taken place at that time. East Renfrewshire’s planners indicated they had no knowledge of any proposal at that time, although an e-mail from Willy Findlater of LRV dated 4th January 2011 stated that “East Renfrewshire Council is already fully aware of the proposals.”

2. Context

The EU has identified and enshrined in law, the guiding principles for Waste Management.

A fundamental principle in these objectives is the ’Waste Hierarchy’. This is shown below but can be summarised as “Reduce, Re-use, Recycle.”

Each member state is expected to establish its own response to these directives. As can be seen, energy recovery is second to last in the preferred strategies for dealing with waste.

Under a 1999 EU directive, all member states must reduce the amount waste buried in landfill sites by 25% of the 1995 levels by 2010, 50% by 2014 and 65% by 2020. Scottish authorities are nowhere near achieving these targets and the outcome at UK level will be penalties imposed by the EU which could be as much as £180 million a year.

The Scottish Government undertook public consultation in 2009 on its ambition to create a ‘Zero Waste Plan’ for the country. Consequently a draft plan was prepared in June 2010 and second stage consultation concluded on 7th January 2011.

The plan aims to achieve:A zero waste Scotland, where we make the most efficient use of resources by minimising Scotland's demand on primary resources, and maximising the reuse, recycling and recovery of resources instead of treating them as waste.

The Government’s vision is for:A Scotland where resource use is minimised, valuable resources are not disposed of in landfills, and most waste is sorted into separate streams for reprocessing, leaving only limited amounts of waste to go to residual waste treatment, including energy from waste facilities.

The plan will introduce a long term target of 70% recycling for all waste arising in Scotland by 2025.

In addition, the Scottish Government will:

Encourage and support investment in innovative resource management technologies and will support the utilisation of renewable energy generated from resource management facilities, thereby contributing to Scotland's renewable energy targets.

In relation to waste management facilities and waste to energy projects specifically, the plan refers to the following:

Identifying Potential Waste Management Sites: Modern waste management infrastructure is designed and regulated to high standards and is similar to other industrial processes. Subject to detailed site specific considerations, waste management facilities can be considered appropriate for sites allocated in development plans for employment and industrial use.

Development plans must safeguard all active and consented waste management sites and identify appropriate locations for all waste management facilities, where possible on specific sites or supported by a policy framework to facilitate development.

Every effort should be made to ensure that proposed waste management facilities for all wastes are consistent with neighbouring local authority approaches in order to provide adequate capacity. Where local authorities are working singly or in collaboration to address their waste responsibilities, this may be discharged in the development plan or through joint development plan approaches, with site allocations informed by evidence on waste data flows in and out of the plan area.

The following locational criteria should be considered by planning authorities and developers when identifying and assessing sites for waste management facilities to ensure that they support waste infrastructure investment and are in the most appropriate locations. More detailed guidance will be provided in PAN 63.

Potential suitable sites for waste management activities include:• Industrial areas • Degraded, contaminated or derelict land • Working and worked out quarries • Sites that have the potential to maximise the potential for the re-use of waste heat through co-location with potential heat users • Existing or redundant sites or buildings that can be easily adapted • Existing waste management sites, or sites that were previously occupied by waste management facilities • Sites accessible to railways, waterways or the trunk and principal road network junctions.

Links to Transport InfrastructureRelevant considerations in the siting of installations will include access to the transport network, including road, rail and waterways. All decisions regarding the location of waste management infrastructure should take into consideration how wastes and end products are transported to and from the site, minimising unnecessary travel.

Impact on EnvironmentAs with all other types of development, proposed waste management facilities should be located in sites where potential impacts on the human, built and natural environment can be minimised. There may be a requirement under the Environmental Impact Assessment (Scotland) Regulations 1999 for an Environmental Impact Assessment (EIA) to be prepared to assist in the consideration of any potential likely significant environmental impacts.

Heat and Power UseAny sites identified specifically for energy from waste facilities (including combustion of biogas resulting from Anaerobic Digestion treatment) should allow links to be made to potential users of renewable heat and energy. Such schemes are particularly suitable in locations where there are premises nearby with a long-term demand for heat.The existing National Waste Plan for Scotland was prepared in 2003 and will be superseded by the new Zero Waste Plan.

The existing plan included the following targets:

• Stop the growth in municipal waste by 2010• Achieve 25% recycling and composting of municipal waste by 2006 and 55% by 2020• Recover energy from 14% of municipal waste• Reduce landfilling of municipal waste from around 90% to 30%

Flowing down from the Zero Waste Plan, each local authority singly, or in sensible collaboration with nearby authorities, must establish a strategy for their area as part of Local Development Plans. East Renfrewshire’s Plan is currently at an advanced stage, with the adoption of the Plan expected in February 2011. It is clear that there are some adjustments required to align with the Zero Waste Plan but these may be just cosmetic in nature.

A key element of the current draft is the land allocation within the council area. This clearly shows that Loganswell area is not only Green Belt but bounded by “Sites of Importance for Nature Conservation” and “Special Scientific Interest”. The actual space is also designated as potential site fro renewable energy, but in this context specifically states “Windfarms”.

On the face of it, the Loganswell site would appear to conflict with many of the national and local criteria set out above, particularly in relation to siting of the facility.

It is safe to say that Scotland’s performance against national waste targets has been disappointing. Municipal waste has continued to grow at the level of 1% per year and few local authorities have made sufficient progress with their recycling targets. Notably, East Renfrewshire is seen as one of the best at the moment.

Glasgow City in particular has very serious problems. Its only landfill site at Cathkin Braes is almost at capacity. The Polmadie waste facility contains an incinerator which no longer meets current operating standards and is due for replacement.

As the Evening Times revealed in November 2010, Glasgow is seeking a private partner to help it dispose of and annual total 150,000 tonnes of residual waste after recycling, in a contract that may be worth £100 million. Options to site waste to energy facilities within the city boundary, including on the Polmadie site, have met strong local residential and political opposition. Local representatives have actually argued that such facilities should be located outside of the city.

As with other local authorities, the headache can only get worse for Glasgow City by 2014. On 1st April 2010, landfill tax paid by councils rose to £48 per tonne. This will increase by £8 per tonne each year to 2014/15.

Heat and Power UseAny sites identified specifically for energy from waste facilities (including combustion of biogas resulting from Anaerobic Digestion treatment) should allow links to be made to potential users of renewable heat and energy. Such schemes are particularly suitable in locations where there are premises nearby with a long-term demand for heat.The existing National Waste Plan for Scotland was prepared in 2003 and will be superseded by the new Zero Waste Plan.

The existing plan included the following targets:

• Stop the growth in municipal waste by 2010• Achieve 25% recycling and composting of municipal waste by 2006 and 55% by 2020• Recover energy from 14% of municipal waste• Reduce landfilling of municipal waste from around 90% to 30%

Flowing down from the Zero Waste Plan, each local authority singly, or in sensible collaboration with nearby authorities, must establish a strategy for their area as part of Local Development Plans. East Renfrewshire’s Plan is currently at an advanced stage, with the adoption of the Plan expected in February 2011. It is clear that there are some adjustments required to align with the Zero Waste Plan but these may be just cosmetic in nature.

A key element of the current draft is the land allocation within the council area. This clearly shows that Loganswell area is not only Green Belt but bounded by “Sites of Importance for Nature Conservation” and “Special Scientific Interest”. The actual space is also designated as potential site fro renewable energy, but in this context specifically states “Windfarms”.

On the face of it, the Loganswell site would appear to conflict with many of the national and local criteria set out above, particularly in relation to siting of the facility.

It is safe to say that Scotland’s performance against national waste targets has been disappointing. Municipal waste has continued to grow at the level of 1% per year and few local authorities have made sufficient progress with their recycling targets. Notably, East Renfrewshire is seen as one of the best at the moment.

Glasgow City in particular has very serious problems. Its only landfill site at Cathkin Braes is almost at capacity. The Polmadie waste facility contains an incinerator which no longer meets current operating standards and is due for replacement.

As the Evening Times revealed in November 2010, Glasgow is seeking a private partner to help it dispose of and annual total 150,000 tonnes of residual waste after recycling, in a contract that may be worth £100 million. Options to site waste to energy facilities within the city boundary, including on the Polmadie site, have met strong local residential and political opposition. Local representatives have actually argued that such facilities should be located outside of the city.As with other local authorities, the headache can only get worse for Glasgow City by 2014. On 1st April 2010, landfill tax paid by councils rose to £48 per tonne. This will increase by £8 per tonne each year to 2014/15.

Another of the main problems in trying to assess the effectiveness technically and commercially of waste to energy schemes is that most of the available information comes from enterprises that are either operating such facilities or propose to do so – there are few independent or dispassionate sources of information. Additionally, regulators freely admit that their criteria and methods for measurement of the environmental performance of waste to energy systems are currently not up to scratch.

LRV has been at pains to point out that Loganswell will not include “mass burn incineration.” This is misleading. Plasma arc and comparable technologies, such as pyrolysis and gasification, are all defined as incineration by the European Union and the US Environmental Protection Agency. Therefore, since Loganswell would undertake incineration, and given the sheer quantity of material that would be accepted at the site, the process can only be described as “mass burn incineration” on an industrial scale.

4. Timescale

LRV state that they are aiming to have the Loganswell incinerator up and running by 2014 – conveniently coinciding with top rate increases in landfill taxes.

By deduction, sod cutting and construction would have to commence by early 2012 at the very latest, which suggests LRV hope to go through all consultations and formal planning procedures in the course of this year.

LRV submitted their scoping document to the Scottish Government in November/December 2010. They are now required under Section 36 to initiate local public consultation before preparing a formal planning proposal for the Scottish Government – they have indicated that consultation will be underway by February 2011.

Under Section 36 of the Electricity Act 1989 they will be required to complete the following:

• Scoping opinion with statutory consultees such as SNH and SEPA• A formal Section 36 application to Scottish Ministers• Receipt of formal responses from statutory consultees• If the local authority has objected to the proposal, then Scottish Ministers must decide if a public inquiry is necessary• A final ministerial decision on consent, consent with conditions or outright rejection• If consent is granted, further consents are still required from SEPA

In terms of the actual construction of the incinerator, there are certain problems that may make this difficult. Most of the specialist builders who could take on large scale projects like this either are or will be engaged on work for the New Southern General and the Commonwealth Games.

At UK level, there are also other major infrastructure projects underway, including preparation for the 2012 London Olympics. This suggests that LRV may have to bring in contractors from Europe or further afield to have a chance of completing the project on schedule, which somewhat undermines their job creation claims.

It is also worth noting that the Peterborough waste to energy facility, which LRV cite as an example, was fitted out and equipped through a contract with a Malaysian company.

However, there may be reasons why LRV might only wish to concentrate on securing planning permission and they may actually be unconcerned with any of the construction and logistical problems that follow.

5. A Closer Look at LRV

No company can claim to have experience of developing plasma arc incineration on the scale proposed for Loganswell. However, a brief review of the CVs of the Directors of LRV reveal that, with one possible exception, none of them have had any experience whatsoever with this type of technology before, nor any other form of processing on this scale.

Financial reports on LRV reveal that it has next to no capitalisation and certainly not the £640 million needed to build the incinerator. It is also apparent that Brian Kilgour’s other business interests have high levels of debt.

Currently gate prices for waste range from £60-£90 per Tonne or around £110 million per year in revenue from waste receipt alone. Expansion and leasing to other waste management specialists and manufactures within the “village” represents another significant revenue stream. Even taking out the initial capital outlay, and ongoing operations costs, these developments represent a huge pot of gold for waste operators. Ultimately, this comes from us either as consumers or Council/Income Tax payers. So, we not only suffer the consequences of the development, but we actually pay for the privilege.

The following conclusions can be reached:

• To achieve the financial backing necessary, LRV will have to attract investment from third parties• Getting planning permission for Loganswell would be only the first step in gaining sufficient credibility with potential backers• Obtaining early commitments for waste management contracts from major commercial and municipal interests – such as Glasgow City’s £100 million contract - would enable LRV to borrow funds and secure investment to build the incinerator – LRV have not answered direct questions as to whether or not they are in talks with Glasgow or other authorities• To ensure a reasonable return on that level of investment, the guaranteed annual income stream would have to be very large – this could most easily be achieved by setting up contracts with a variety of local authorities, all facing common waste management problems – consequently, the 1.5 million tonne waste input figure quoted by LRV for Loganswell may actually turn out to be on the cautious side

However, it may not be LRV’s intention to raise the capital needed. We can speculate that there may be three other possibilities:

• LRV may simply be a ‘local’ front for a global waste management player, essentially contracted to use ‘native’ skills and knowledge to get the proposal through the initial planning stages

• LRV do not intend to do any more than obtain planning permission to develop Loganswell – once obtained they will simply sell the site with permissions attached to the highest bidder and reap huge profits. This may explain why none of the LRV team have any strong expertise in large scale waste management projects• LRV have submitted an initial proposal for a mammoth facility in the expectation that this would cause great community concern and anger; in the face of this they could withdraw their current application, re-present it based on a much smaller operation and attempt to convince the community and authorities that they have listened to local concerns and responded. In actuality they will perhaps gain permission for the size of plant they really intended all along

Whatever the case, there are two clear messages for the local community:

• The best opportunity to get the Loganswell project stopped is during the earliest planning stages.• Any guarantees or concessions given to the community by LRV are not worth the paper they are written on as LRV may not stick around to see them through

6. Implications for Newton Mearns and the Southside

LRV claim the incinerator would be well away from “built up areas” and that traffic impact would be managed. This is disingenuous in the extreme.

The largest such facility in Europe will most certainly have very serious impacts on this community:

• Loganswell is only a few minutes from Mearns Cross• Prevailing winds mean that any airborne toxins and residues emerging from stacks and unproven plasma arc technology will be deposited on Newton Mearns and the southside – there may be unacceptable long-term public health implications as a result, especially for young children• Accepting LRV’s claim that 1.5 million tonnes of waste will be processed at Loganswell, this would be equivalent to 350 – 400 journeys using ‘standard’ refuse vehicles terminating in Newton Mearns each day for waste receipt only. This does not include return journeys or vehicles uplifting processed waste products and the figure may well increase significantly if LRV were successful in gaining additional, especially municipal, contracts. Potential “village” partners will add to this traffic stream• LRV’s claim that these vehicle journeys have no additional impact as the “vehicles are already on the road network” is a scanty figleaf for the fact that vehicles carrying potentially hazardous loads making their way to other facilities across the country will now all be concentrated in Newton Mearns, along with all the attendant problems of carbon emissions and diesel particulates from exhaust fumes, noise pollution, traffic congestion and disruption, danger to pedestrians and other road users and wear and tear on the road network. Anyone who has dealt with HGV drivers will confirm that they are unlikely to stick to using the M77 or avoiding residential areas if this cuts their journey times. Crucially, LRV have admitted that, as well as the M77, these vehicles would be using the “associated road network” – this is precisely where Newton Mearns and much of the southside sits

• Another significant portion of our green belt will be lost forever. LRV’s comparisons between Loganswell and the Whitelees Wind Farm are specious: the latter when superseded can be removed and the landscape re-instated – if the incinerator closes the farm land will remain lost to us and quite possibly will be contaminated • Apart from the incinerator plant itself, further disruptive construction work would be necessary to put in road access capacity (given the number of vehicles going to the site this may have to include a lorry park) as well national grid infrastructure to enable electricity generated onsite to be transmitted into the system• Property values will undoubtedly suffer – an area lying in the shadow of a massive industrial facility is likely to be less than appealing to buyers. Families who have saved and worked hard to move into this area may see their efforts rewarded with negative equity• The community benefits on offer by LRV are derisory and effectively non-existent. They consist of a visitor centre and a promised £250,000 a year that would not even cover the annual bill for additional wear and tear on local roads• If LRV are successful in gaining further contracts, this will certainly lead to additional heavy road traffic, more danger from pollution and possibly further expansion of the site• Local job creation prospects are limited – specialist expertise to build and equip the plant will have to come from elsewhere and the numbers of staff actually required to keep the site operational are likely to be low

So, who actually benefits?

LRV obviously makes money one way or another. Local authorities and commercial interests get a quick short-term fix for their waste management problems. That’s it. There is absolutely nothing to be gained by this community or by residents in neighbouring areas.

At national level, a facility like Loganswell might actually set recycling targets back by causing more material that could be recycled to be burned to make the incinerator viable. Examples of this are already evident in Dumfries and Galloway. Absolutely nothing would be achieved in minimising generation of waste in the first place, or in reducing energy and natural resources used in its creation.

In short, LRV is simply making use of a ‘green flag of convenience’ as a moral argument to try and get around planning regulations and the objections of residents.

7. Designing a Campaign

This is probably the most serious issue ever to threaten the wellbeing of Newton Mearns and neighbouring communities in East Renfrewshire and Glasgow.

The response to this level of threat requires co-ordinated community action – and it has to come together fast if there is to be any chance of stopping this monstrous project.

Firstly, the campaign must have an ‘umbrella’ theme and slogan to ensure that all residents realise the scale of the threat. Secondly, information has to be shared far and wide – this will be accurate and accessible and will counter the reassuring but misleading noises being put out by LRV. Thirdly, the information must result in widespread action from as many people as possible – objections and concerns must not be dismissed as merely the ravings of a few ‘NIMBYs;’ it must be made clear to politicians especially that our communities do not want this incinerator and that we are prepared to take (for them) career-ending action if they do not listen.

We need to favourably influence by all legal means possible the following:

• Local residents and business interest groups• Statutory Bodies – Planning, SEPA, SNH• Local and National Politicians (possibly the most unpredictable)• Civil service administrators• Government Ministers

It is proposed that that a formal campaign group be established. This should be named something like:

Don’t WasteThe Mearns or Don’t Waste East Renfrewshire with the constant tagline ‘Stop the Incinerator,’ or perhaps ‘LRV? UFO.’

We should organise this as if it were a professional industrial business concern executing a major project. In other words, define an organisational structure, the individual components of which have clear areas of responsibility to support the whole effort. Likely functions or sub groups could be:

This in all likelihood will involve significant personal time commitment from people who already have ‘day jobs’. It must therefore make efficient and effective use of this precious time by being structured in our communications, meetings etc.

First and foremost, the campaign must remain, in itself, united to be able to exert the desired influence.

The following activities are seen as key:

• Establishing the Group’s status as an interested party in the Section 36 engagement process, so that the group can put forward a formal submission as a non-statutory consultee and any accompanying public petition• Raising a petition in the Scottish Parliament’s Public Petitions Committee• Appointing a co-ordinating spokesperson who is able to provide media interviews and briefings

• Nevertheless, ensuring many different local voices are heard – residents encouraged to sign petitions, individually write letters to papers, politicians and to LRV itself – this may include a massive ‘letter to the editor’ signed by enough people for it to take up a full page of The Herald, South Glasgow and Eastwood Extra and Eastwood Today• Contact with international and national organisations and campaigners to seek advice and to ask them to submit media releases, letters and reports and planning submissions to challenge LRV’s case• Assembly of a panel of ‘experts’ able to advise the campaign in terms of technical reviews of LRV’s environmental impact assessment, technical specifications, finances and legal status – we may be able to recruit people with the necessary industry, business and academic skills and experience from the local community• Establish a campaign website with links to relevant reports and provision of information which critiques LRV’s case• Locate people with graphic design and Photoshop skills who can provide diagrams, an accurate map showing the size and proximity of the incinerator and mocked photos showing roads gridlocked with refuse vehicles for use in leaflets and the website• A division of roles at and points to raise at public meetings organised by LRV, so that organisers can’t try to block one person asking all the questions• Organisation of our own public meetings to which we would invite politicians as well as experts who can offer impartial advice• An attempt to create cross-party political support for the campaign following media-led pressure on all local politicians to ‘out’ themselves on their attitude to the proposal• Exploitation of the May elections – by publishing all candidates views on the LRV proposals and, if necessary, encouraging residents not to vote for those who either support or won’t actively oppose the incinerator• If ERC is found to have encouraged this proposal, or intends to put forward a supportive submission in the planning process, we must consider the real possibility of putting up candidates in May whose purpose once elected would be to reverse Council policy on the matter and then stand down once this was achieved• A regular Saturday presence at Mearns Cross shopping centre and neighbouring community streets – and in close proximity to LRV’s promised information centre• Approach local shops and businesses and explain that the LRV incinerator would bring decline to the area, affect profits and restrict access due to the road congestion caused – they could be asked to display posters and to contribute to a fighting fund (Estate agents in particular can be targeted as they may stand to lose most if the project goes ahead)• Door to door visits to raise awareness• A letter to Glasgow City’s Environmental Services Director to confirm if LRV have been in talks about taking on the City’s municipal waste contractors and/or substituting Polmadie• Fundraising collections• Production of a leaflet• Posters• Placards• If sufficient money can be made, we must place advertisements in the local papers• Badges• Media releases

We need to bring home to residents just how damaging this incinerator will be to their way of life. We must keep the messages, clear, simple and unambiguous.

• This is a huge industrial development right on our doorstep• It is using technology untried in this size and application• It conflicts with European, National and Local development and sustainability intentions• It is and will continue to be a blight on important greenbelt amenity• It represents a significant community health risk now and for generations to come

We must not enter into a technical dialogue in public with LRV and should not use their weasel word ‘Green’ terminology. All letters, interviews and web content must constantly use and re-use phrases such as ‘Green flag of convenience’ to emphasise that all LRV’s environmentally friendly talk is simply window dressing, and we must always refer to the project as the ‘waste incinerator’ or ‘Europe’s largest waste incinerator’ and not the fluffy ‘Lifetime Recycling Village.’ If we have to refer to the company, we call them LRV.

The messages we need to get to the community include:

• The incinerator will change your personal lifestyle and your wider community for the worse• The incinerator is absolutely enormous – it is a major industrial plants bring as many as 400 heavy vehicles through our streets each day and it is six times the size of the new Southern General or • More of our green belt will be destroyed forever for no real, long-term environmental benefits• It will cause local pollution and as yet unknown effects on the environment and public health, especially of our children• It uses relatively new unproven technologies – the long term effects of which are not fully known • There will be huge disruption caused by enormous numbers of heavy vehicles carrying hazardous waste in close proximity to our community• Even if we get to choose the paint finish on the exterior of the buildings and the variety of grass planted on the roof, it is still a major industrial operation where poisonous waste is being handled• This is a waste incinerator, plain and simple – don’t let them fool you• This will be the largest incinerator in Europe, effectively bring a massive industrial plant right onto our doorstep • The economic case for an incinerator of this size only makes sense if major industrial waste streams from across Scotland and municipal waste streams for neighbouring local authorities can be directed to the site – this means the Mearns will literally become a dumping ground for much of the nation’s unwanted and hazardous waste • The jobs figures don’t stack up – contractors are very likely to have to be imported from outwith Scotland and the UK. Of the remaining long-term jobs, few will go to locals• Other projects in the UK are being located on existing waste or industrial sites – how can this giant industrial plant be justified on greenbelt in close proximity to a suburban residential area?• We freely admit to being NIMBYs – no rational human being in any community would want an industrial scale incinerator park in close proximity to their houses, especially if it destroys local countryside and poisons our people• We might be NIMBYs but we are also NIYBYs – we don’t think a facility like this should be situated near any other residential community anywhere else

As you are all now aware East Renfrewshire Council have started the formal Consultation process regarding the proposal which they have put forward. We wish to highlight to you that IT IS NOT ACCURATE to suggest that the proposal contained in the Consultation document was the option proposed or supported by the Parent Council members of the Short Life Working Group (SLWG).

We would ask you to follow the link to the minutes of the three meetings of the SLWG from which you will note that we asked for a three strand proposal to be consulted upon which sought to provide a short, medium and long term solution to the impending problem of overcrowding at St Ninian's.

This three strand proposal which all affected schools asked to be consulted upon and investigated in terms of feasibility by ERC sought

1. To Protect the current admission rights for all children currently at any of the affected schools.

2. If and only if a school (Primary or Secondary) reaches the point of over-subscription then priority of admission be given to children who hold a baptismal certificate into the Catholic faith.

3. That the council should plan now for long term provision of sufficient schools in the Eastwood area for the increasing numbers of people wishing to access denominational Catholic education at both Primary and Secondary level.

Your Parent Council have invested a great deal of time in finding out as much as possible about the issues here and wish to stress to you that the consultation process is highly relevant to the future of St Cadoc's Primary.

It is tempting at first blush to assume that because the proposal appears to affect the two feeder primaries and not us, that children of our school are unaffected.

It is the firm view of your Parent Council that the issue of overcrowding at St Ninian's will not be solved in the long term unless another solution is found.

The planned Greenlaw Project, inward migration in order to be within the newly created smaller catchment area if the proposal is given effect and the fact that our school has now reached capacity mean this issue of overcrowding is likely to be upon the three remaining schools again within a few short years.

It should be noted that Our Lady of the Missions Primary already has temporary portacabins as classrooms to accommodate over capacity.

We would also point out that the Response Form supplied with the Consultation Document appears to invite a Yes or No response to the proposal.

As this is a formal consultation we urge each interested party to make their detailed views known and not simply respond Yes or No. We strongly urge you to make a detailed response.

You can also attend the public meetings which ERC will hold at Woodfarm High School at 7:00pm on Wednesday 29 September 2010, and 7:00pm on Monday 4 October 2010 to ask any questions you may have.

Whatever your view is on the subject, please make it count by responding to the consultation document by the closing date of Friday 5th November.

You may also be aware that ERCl plan to send independent educational specialists to St Cadoc's and all other affected schools as part of their legal duties under the new laws governing formal Consultations.

We have spoken with Mr Duffy about this and he has assured us that the persons in question are highly experienced and that any parent who does not wish their child to be spoken to about this issue can opt out of the process.

You may also wish to note that the children will all be given a reply form for the consultation in class when the talk takes place.

There is NO requirement on the child to fill it in at school or indeed at all so you may feel you want to tell your child to bring the form home to discuss with you if you have concerns about them completing same in class.

We will keep you informed of any new information which may assist you in regard to the consultation process.

Just over twenty-five years ago following a campaign by Parents from across the current catchment area and the Church, the first - and still only - Catholic secondary school in Eastwood was established. This consultation seeks to make the most significant change to your school community in a generation. It has SIGNIFICANT implications for ALL parents in the catchment area - BOTH IN GLASGOW AND IN EAST RENFREWSHIRE - who seek to send their children to St Ninian’s High School. Please try to make this meeting, at which your Parent Council can help to inform your opinions on the consultation’s implications.

In the meantime, we highlight some points for your consideration:

? The consultation ignores input from the six Parent Councils who took part in a Working Group established by East Renfrewshire Council (ERC) before the summer holidays. It is incorrect to suggest that the proposal is broadly representative of the views expressed by the working group.

? Your Parent Council asked ERC that a three-strand solution be explored for which there was broad agreement:

1. Protect current admissions rights for all our children (regardless of their religion) currently enrolled in any of our five feeder primaries.

2. If (and only if) the school is over-subscribed, then prioritise admissions for baptised Catholics living within the catchment (all pupils currently enrolled in primary have protected rights as above).

3. Increase provision in Eastwood for all children who want access to a Catholic education.

? The consultation fails to address the complexity of the total problem. Even if priority admissions rights are taken away from children at St Angela’s and St Vincent’s, house building and migration into Eastwood mean that East Renfrewshire residents who seek admission to Catholic education are likely to face this issue in the very near future. In spite of extensions and use of “temporary” huts, Our Lady of the Missions operates above capacity and has children “domiciled” in other primaries, St Cadoc’s is at capacity and child numbers at St Joseph’s approach capacity. Careful planning in the non-denominational sector has assured ample room for growth in that sector. Nine non-denominational primaries cover the same area as three ERC Catholic primaries. None of the four non-denominational secondary schools has faced a proposal to deny their young people access to a school in the Eastwood area.

? It is important that if you believe that when St Ninian’s is oversubscribed then admissions policy (as opposed to only placing requests policy) should givepriority to baptised Catholics, you raise this matter in your response to the consultation.

1. Other Scottish Local Authorities already have admissions policies that when a school is oversubscribed priority can be given to children of the denomination.

2. The Equality and Human Rights Commission’s website notes that prioritisation is permitted.

3. Minute of third meeting of Short-Life Working Group - comments re meeting held with Cabinet Secretary for Education and Lifelong Learning.

4. St Ninian’s exists because the Church was able to satisfy ERC of the number of Catholic children requiring Catholic education (a requirement to establish a Catholic school). While Catholic schools admit and warmly welcome children from all faiths or none, their primary purpose is to educate Catholic children.

? Parents and pupils can respond to the consultation. If your family makes a combined response, then it will count as one. Each entitled individual in your family can make their own individual response.

Parent Forum meeting: St Ninian’s on Tuesday 14 September 2010 at 7:30pmTo discuss and inform opinions on the Local Authority’s Consultation

Just over twenty-five years ago following a campaign by Parents from across the current catchment area and the Church, the first - and still only - Catholic secondary school in Eastwood was established. This consultation seeks to make the most significant change to your school community in a generation. It has SIGNIFICANT implications for ALL parents in the catchment area - BOTH IN GLASGOW AND IN EAST RENFREWSHIRE - who seek to send their children to St Ninian’s High School. Please try to make this meeting, at which your Parent Council can help to inform your opinions on the consultation’s implications.

In the meantime, we highlight some points for your consideration:

• The consultation ignores input from the six Parent Councils who took part in a Working Group established by East Renfrewshire Council (ERC) before the summer holidays. It is incorrect to suggest that the proposal is broadly representative of the views expressed by the working group.

• Your Parent Council asked ERC that a three-strand solution be explored for which there was broad agreement:a) Protect current admissions rights for all our children (regardless of their religion) currently enrolled in any of our five feeder primaries.b) If (and only if) the school is over-subscribed, then prioritise admissions for baptised Catholics living within the catchment (all pupils currently enrolled in primary have protected rights as above).c) Increase provision in Eastwood for all children who want access to a Catholic education.

• The consultation fails to address the complexity of the total problem. Even if priority admissions rights are taken away from children at St Angela’s and St Vincent’s, house building and migration into Eastwood mean that East Renfewshire residents who seek admission to Catholic education are likely to face this issue in the very near future. In spite of extensions and use of “temporary” huts, Our Lady of the Missions operates above capacity and has children “domiciled” in other primaries, St Cadoc’s is at capacity and child numbers at St Joseph’s approach capacity. Careful planning in the non-denominational sector has assured ample room for growth in that sector. Nine non-denominational primaries cover the same area as three ERC Catholic primaries. None of the four non-denominational secondary schools has faced a proposal to deny their young people access to a school in the Eastwood area.

• It is important that if you believe that when St Ninian’s is oversubscribed then admissions policy (as opposed to only placing requests policy) should give priority to baptised Catholics, you raise this matter in your response to the consultation. a) Other Scottish Local Authorities already have admissions policies that when a school is oversubscribed priority can be given to children of the denomination.b) The Equality and Human Rights Commission’s website notes that prioritisation is permitted.c) Minute of third meeting of Short-Life Working Group - comments re meeting held with Cabinet Secretary for Education and Lifelong Learning.d) St Ninian’s exists because the Church was able to satisfy ERC of the number of Catholic children requiring Catholic education (a requirement to establish a Catholic school). While Catholic schools admit and warmly welcome children from all faiths or none, their primary purpose is to educate Catholic children.

• Parents and pupils can respond to the consultation. If your family makes a combined response, then it will count as one. Each entitled individual in your family can make their own individual response.

Parent CouncilSt Angela’s Primary Glasgow G46 10 September 2010Dear Parent/Guardian,Parent Council Information Session: St Angela’s on Tuesday 14 September 2010 from 6:30pm until 8:00pm Parent Forum: St Angela’s on Monday 20 September 2010 at 7:15pmEast Renfrewshire Council Consultation to remove St Angela’s from the catchment area of St Ninian’s High School as of school session 2012/13Prior to attending either or both of the meetings please take some time to fully read over the consultative document. Both opportunities are designed to provide further information and discuss and inform opinions on the East Renfrewshire Consultation.Just over twenty-five years ago following a campaign by Parents from across the current catchment area and the Church, the first and the only Catholic secondary school in Eastwood was established.This consultation seeks to make the most significant change to your school community in a generation. It has SIGNIFICANT implications for ALL parents in the catchment area - BOTH IN GLASGOW AND IN EAST RENFREWSHIRE - who seek to send their children to St Ninian’s High School. Please try to make time for meeting parent council members at the information session and/or the full parent meeting, at which your Parent Council can help to inform your opinions on the consultation’s implications.In the meantime, we highlight some points for your consideration:• The consultation ignores input from the six Parent Councils who took part in a Working Group established by East Renfrewshire Council (ERC) before the summer holidays. It is incorrect to suggest that the proposal is broadly representative of the views expressed by the working group.• Your Parent Council asked ERC that a three-strand solution be explored for which there was broad agreement:

a) Protect current admissions rights for all our children (regardless of their religion) currently enrolled in any of our five feeder primaries;

b) If (and only if) the school is over-subscribed, then prioritise admissions for baptised Catholics living within the catchment (all pupils currently enrolled in primary have protected rights as above),

c) Increase provision in Eastwood for all children who want access to a Catholic education.

• The consultation fails to address the complexity of the demand for a Catholic education. Careful planning in the non-denominational sector within the area has assured ample room for growth in that sector. Nine non-denominational primaries cover the same area as three ERC Catholic primaries. None of the four non-denominational secondary schools has faced a proposal to deny their young people access to a school in the Eastwood area. The situation in the Glasgow part of the delineated catchment area is not too dissimilar.• It is important that if you believe that when St Ninian’s is oversubscribed then admissions policy (as opposed to only placing requests policy) should give priority to baptised Catholics, you raise this matter in your response to the consultation.

a) Other Scottish Local Authorities already have admissions policies that when a school is oversubscribed priority can be given to children of the denomination.

b) The Equality and Human Rights Commission’s website notes that prioritisation is permitted.

c) Minute of third meeting of Short-Life Working Group - comments re meeting held with Cabinet Secretary for Education and Lifelong Learning.

d) St Ninian’s exists because the Church was able to satisfy Strathclyde Regional Council of the number of Catholic children requiring Catholic education (a requirement to establish a Catholic school). While Catholic schools admit and warmly welcome children from all faiths or none, their primary purpose is to educate Catholic children.

• Parents and pupils can respond to the consultation. If your family makes a combined response, then it will count as one. Each entitled individual in your family can make their own individual response.

short,medium and long term proposal put forward at the SLWG and supported by themajority of the parent councils

Proposal for Short Life Working Group

Short termAll children, irrespective of their religion, currently enrolled in any feeder primary school and who have a priority right of admission to St Ninian’s will retain that right until they enter St Ninian’s. The Local Authority should have time to plan for any issues that might arise without seeking to remove current rights from any children.

Medium TermIf St Ninian’s is oversubscribed, then baptised Catholic children living within the current catchment area will get first priority right of admission. A Catholic school comes into existence when the Catholic Church satisfies a Local Authority that there are sufficient numbers of Catholic children requiring a Catholic education. St Ninian’s exists primarily for the education of Catholic children living within the current catchment area. Children covered by short-term provision have their rights assured (see above).

Long TermOur Local Authority must plan carefully for the denominational sector. The Council require to plan now so that sufficient provision is delivered in the long term. Our Local Authority has clearly planned well for the non-denominational sector. Parents of other faiths and none also want their children to be educated in a Catholic school. The Local Authority should provide sufficient room for growth in the denominational sector.

Background

East Renfrewshire Council (ERC) has established a Short Life Working Group (SLWG) on “Issues pertaining to Admissions and Placing Requests into St Ninian's High School, Giffnock". Attendees include Councillors and senior officials of East Renfrewshire and Glasgow City Council, Representatives of the Diocese of Paisley and the Archdiocese of Glasgow, Parent members from all six affected Parent Councils; Our Lady of the Missions, St Angela's, St Cadoc's, St Joseph's, St Ninian's, St Vincent's. The SLWG is trying to decide on solutions to recommend for consideration by ERC’s Education Committee. If the Education Committee decides that a wider consultation is required, then individuals will be able to make their own response, as was the case with the consultation conducted in November 2009.

Throughout the last few months, Chairs and reps from the six affected Parent Councils have also maintained close contact with each other and have held several cluster meetings, working with common cause to find solutions that respect the legal and moral rights of all Parents making up the St Ninian’s family.

There is no simple, quick fix solution to this very complex issue. Simply removing a feeder primary school by changing the catchment area won’t solve the problem; all our feeder primaries continue to grow. Indeed such action would immediately and massively increase the number of placing requests from any part of the country that must legally be granted admission to St Ninian’s. This, in turn, would dilute local community bonding, jeopardise the character of the school and affect its ethos. Removing part of the St Ninian’s family would also set a precedent to remove another primary school in the near future as increasing numbers of families within the former Eastwood (Busby, Clarkston, Giffnock, Newton Mearns) area elect Catholic education.

St Ninian’s has already faced supply and demand issues. During the 1990s, there was a proposal to remove right of entry to St Ninian’s from the children at St Cadoc’s. This proposal was defeated and St Ninian’s got an extension. No other secondary school in our area has faced a proposal to change its catchment area.

Substantial numbers of new house builds are underway in Newton Mearns. This will also increase pressure on St Ninian’s from within East Renfewshire. Figures provided by ERC demonstrate that there is room for substantial growth in the non-denominational sector. The level of provision and delivery of Catholic education in our locale needs careful future planning.

The proposal above outlines a set of measures which taken together already has broad agreement across the entire St Ninian’s family. Proceeding on the principle of no harm to any feeder primary school within the St Ninian’s family and those who currently enjoy a first priority right to attend St Ninian’s, the proposal addresses the short, medium and long terms and provides a solution that fully respects the rights of the entire school community.

Please find attached a copy of the response, which your parent council hasmade to the Consultation by East Renfrewshire Council (ERC) regarding StNinian’s. We have made every effort to make this as fair to all and asrepresentative of the feedback we have received as possible.

If you have not already responded to the consultation we urge you to do soas soon as possible. As you are aware, the new time limit for making aresponse is *10th December 2010 and a further public meeting will be held inWoodfarm High School on Wednesday 24th November 2010 at 7pm.* The first twomeetings have been well attended and we would urge you to attend the lastmeeting, even if you have already attended the others, so that your viewsare heard.

The appropriate form for making a response can be downloaded from theCouncil’s website if you don’t have one. Please note that every member ofyour household is entitled to make a response including all children. If aresponse has already been made the council has made it clear it can bewithdrawn or additional information can be submitted.

We are sure this is an issue about which you will wish to make a writtenresponse and in addition to replying to the consultation you can of courselobby your local councillor. Please be aware that you do not need to simplyagree or disagree with the ERC proposal. If, for example, you support theintroduction of a priority entry criteria for baptised Catholic children ifthe school reaches the point of oversubscription then you can make thatclear in your response. We should draw your attention to the recent pastoralletter issued by Bishop Tartaglia in case it is of assistance to you. Thiscan be found at:

We feel the following points require particular clarification in connectionwith ERC’s recent Q & A document:

· The question of balloting has been raised in this document. At thestart of the first consultation process (which did not proceed) ERC statedno interested party they had spoken to regarding the consultation were infavour of balloting and accordingly it was rejected at that time. We do notconsider this to be a viable legal option at this time either.

· ERC acknowledges its proposal would only solve the overcrowdingproblem for 5 years. We feel to fail to deal with the medium and long termand concentrate on the short term is a missed opportunity. This confirms ourview that we will revisit this problem in a few years if a lasting solutionis not found now.

· ERC states that guidance from the Scottish Government makes itclear priority to baptised Catholic children can only be made by placingrequest. We disagree and can confirm the following :

· Other Scottish local authorities already have an admissions policywhen a school is oversubscribed.

I am writing on behalf of the Parent Council of St Cadoc’s Primary to giveour response to the Consultation Document regarding St Ninian’s.

After holding two meetings of our parent forum, issuing a questionnaire andspeaking directly to parents, we can say with confidence that theoverwhelming majority of our parents are opposed to the council’s proposalin the consultation document.

We, the St Cadoc’s Parent Council (and in common with the 4 other parentcouncils representing the other feeder primaries to St Ninian’s and StNinian’s Parent Council) do not support the proposal made in theconsultation. Instead we urge the East Renfrewshire Council (ERC) toimplement the proposals raised by the affected parent councils at the shortlife working group. In particular, we do not wish to see the Glasgow feederschools removed and do not see that this would solve the overcrowdingsituation, but rather just delay the problem facing St Cadoc’s primary alongwith the remaining two other feeder primaries, for a few years. We note inthe recent letter and accompanying question and answer sheet issued by ERCon page 1 they refer to this matter being revisited in 5 to 10 years time.This is a matter of great concern to our parents and we urge ERC to find alasting solution and not one which would only last 5 years. The uncertaintycaused by this consultation process has lasted for over a year already.

We wish to see a priority clause introduced so that if and only if aCatholic denominational school in the East Renfrewshire Council area reachescapacity then first priority must be given to a Baptised Catholic childseeking entry to a Catholic school. We understand there is in fact nobarrier to such a clause being introduced. This suggestion was raised at theShort Life Working Group and no actual barrier other than a potentialchallenge was given for not introducing this policy. At the second publicmeeting ERC’s head solicitor stated that a clause relating to Catholicpriority would not be introduced for reasons of ‘expediency’.

We understand that the Scottish Ministers do not in fact view theintroduction of such a clause as problematic and indeed many local councilsthroughout Scotland currently successfully operate this policy.

We strongly feel that the proposal under consultation will not, by ERC’s ownadmission, solve the problems facing St Ninian’s for more than 5 years. Theproposal set out in the SLWG addresses the long term issues, in particularby the introduction of the priority right of Baptised Catholics in the eventof oversubscription at all Catholic primary and secondary schools withinEast Renfrewshire.